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Type F Reorganizations: How S Corporations Can Use an "F" to Earn an "A"
Tuesday, April 7 at 12pm (CST)
Speaker:
Stephen A. Beck, J.D., LL.M., Partner
About this Webinar
Overview
Subchapter S imposes many requirements for “passthrough” treatment, including the “single class of stock” requirement and limitations on the types of eligible shareholders of an S corporation. These requirements restrict an S corporation’s ability to participate in customary, useful transactions that are available to other types of entities for income tax purposes. Type F reorganizations, however, provide a means of restructuring an S corporation to enable it to participate in these useful transactions, notwithstanding the Subchapter S limitations. This presentation discusses the Type F reorganization requirements and real world examples of how Type F reorganizations may be used to help an S corporation achieve its business objectives in an income tax efficient manner
Key Topics
- Learn the requirements that must be satisfied to support that a transaction qualifies as a tax-deferred “Type F” reorganization under I.R.C. Section 368(a)(1)(F).
- Learn the Federal income tax effects of Type F reorganizations.
- Learn pitfalls that may interfere with qualification for Type F reorganization treatment, as well as the types of transactions that may occur prior to commencement, or after completion, of the reorganization without impacting its qualification as a Type F reorganization.
- Learn real world examples of situations in which a Type F reorganization can help an S corporation achieve its business objectives in an income tax efficient manner.
Details
Course Level: Intermediate
Prerequisite: None
Cost: Free
CPE and MCLE Credit Info:
Course Number: 174316401
CPE Credit: 1.20 Hrs.
MCLE Credit: 1.00 Hr. (Approval Pending)
CFP Credit Info:
CFP Program ID: 347674
CFP Credit: 1.00 Hr. (Approval Pending)
This Event Begins in:
About the Speaker
Stephen A. Beck, J.D., LL.M.
Partner
Mr. Beck is a Board Certified tax attorney who provides Federal income tax and Texas franchise and sales tax advice to businesses of all types and sizes, including Subchapter C corporations, Subchapter S corporations, partnerships, limited liability companies, and entities disregarded for Federal income tax purposes. He advises on tax issues arising during all phases of business operations, including formation, restructuring of ownership interests, acquisitions, dispositions, mergers, consolidations, liquidations, international transactions, issuance of deferred and equity compensation, and business succession planning. He represents businesses and entrepreneurs in a broad range of industries, including professional services, manufacturing, technology, oil and gas, and real estate. He also advises tax-exempt organizations under Section 501 of the Internal Revenue Code.
Mr. Beck also represents individuals, businesses, and estates in tax related controversy matters, including Internal Revenue Service audits, appeals, and litigation in Federal courts, including the U.S. Tax Court and Fifth Circuit Court of Appeals. He also represents taxpayers in franchise and sales tax disputes with the Texas Comptroller of Public Accounts.
Read his full bio here. You can contact Mr. Beck at 214-744-3700 or by email at sbeck@meadowscollier.com.
Register for this FREE webinar!
About Meadows Collier
At Meadows Collier, we are dedicated to supporting continuing education of tax professionals including CPAs, CFPs, and legal experts. We offer free monthly webinars and presentations that provide CPE, MCLE, and CFP credits where applicable. Most firm lawyers hold an LL.M. in Taxation and/or are Board Certified in Tax Law by the Texas Board of Legal Specialization. These free webinars cover a wide array of topics relevant to CPAs, business leaders, legal professionals, and tax specialists. Our webinar topics include federal and state tax updates, IRS enforcement and initiatives, estate planning, corporate tax issues, tax controversy and litigation, and more. Stay informed about the latest developments and gain valuable knowledge from industry leaders. Sign up today to enhance your expertise and navigate the evolving economic landscape with confidence. Tax professionals can rely on Meadows Collier for high quality continuing education.
Founded in 1983, Meadows Collier is a nationally recognized law firm based in Dallas, Texas, specializing in all areas of taxation. Our expertise spans a wide range of complex tax and business matters, including federal and state tax issues, white-collar criminal defense, government regulatory defense, cryptocurrency and digital asset management, wealth planning, corporate law, real estate transactions, and other commercial legal needs. We represent both businesses and individuals in high-stakes litigation, providing solutions for the most challenging tax situations. Tax professionals trust Meadows Collier for comprehensive legal support and expert tax solutions.